On May 6, BPI submitted a comment letter to the FDIC responding to the agency’s Advance Notice of Proposed Rulemaking addressing the FDIC’s comprehensive review of its regulatory approach to brokered deposits.

The letter recommends the FDIC:

Expressively clarify that dual-hatted, dual and affiliate employees are not “deposit brokers”;

Revise its treatment of marketing and advertising relationships and referral arrangements to reflect innovations in technology and marketing methods;